NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: aiam0543OpenMs. Reva B. Fuhrmann, Bookkeeper, Pioneer Machinery, Inc., 1725 Silverton Road, N.E., Salem, OR 97303; Ms. Reva B. Fuhrmann Bookkeeper Pioneer Machinery Inc. 1725 Silverton Road N.E. Salem OR 97303; Dear Ms. Fuhrmann: In your letter of September 15, 1972, you ask for clarification of th records that Pioneer Machinery, Inc., as a manufacturer and installer of truck hoists and racks, is required to keep.; There are several regulations issued by the National Highway Traffi Safety Administration that could apply to Pioneer. The first of these is 49 CFR Part 566, *Manufacturer Identification*. Under this regulation manufacturers of vehicles and equipment to which a Federal motor vehicle safety standard applies must file certain information with the NHTSA. Although Pioneer may not manufacture equipment subject to a standard, it could be a final-stage manufacturer, as defined by 49 CFR Part 568, *Vehicles Manufactured in Two or More Stages*, and subject to both these regulations. I enclose a copy of each. If Pioneer determines it is a 'final-stage manufacturer' then it would also be subject to the obligations of Part 568 (S 568.6) and the requirements of Part 567 (S 567.5) *Certification*, copy enclosed.; If Pioneer is a 'final-stage manufacturer,' it must file quarterl reports of production figures pursuant to 49 CFR Part 573, (S 573.5 (b)) *Defect Reports*. I have also enclosed a copy of this regulation for your review.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5311OpenMr. Richard A. Zander AlliedSignal Automotive Proving Grounds 32104 State Road 2 New Carlisle, IN 46552; Mr. Richard A. Zander AlliedSignal Automotive Proving Grounds 32104 State Road 2 New Carlisle IN 46552; "Dear Mr. Zander: This responds to your letter asking about the fad and recovery requirements of Federal Motor Vehicle Safety Standard No. 105, Hydraulic Brake Systems. I apologize for the delay in our response. You noted that the standard requires vehicles with a GVWR of 10,000 pounds or less to be capable of making a specified number of fade stops 'at a deceleration not lower than 15 fpsps for each stop.' You stated that you are aware of a number of different understandings within the industry of the quoted phrase, and requested an interpretation as to whether vehicles must be capable of maintaining an average deceleration of at least 15 fpsps or a minimum deceleration of at least 15 fpsps. As discussed below, vehicles must be capable of maintaining a minimum deceleration of at least 15 fpsps. By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, et seq.) authorizes the National Highway Safety Administration (NHTSA) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve motor vehicles or motor vehicle equipment. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. Manufacturers must have some independent basis for their certification that a product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. Whatever the basis for certification, however, the manufacturer must certify that the product complies with a standard as it is written, i.e., that the vehicle will pass all applicable requirements if it is tested exactly according to the standard's test conditions and other specifications. Standard No. 105's fade and recovery test requirements are set forth in S5.1.4. These requirements must be met under the conditions prescribed in S6, when tested according to the procedures set forth in S7. See S5.1. The purpose of the fade and recovery test requirements is to help ensure that brakes retain adequate stopping capacity during and after exposure to conditions cause by prolonged or severe use, such as long, downhill driving. The standard specifies two fade and recovery tests for vehicles with a GVWR of 10,000 pounds or less. Each of the fade and recovery tests consists of three parts: (1) baseline check stops, (2) fade stops, and (3) recovery stops. The requirements for the fade stops are set forth in S5.1.4.2(a), which states that: Each vehicle with a GVWR of 10,000 lbs or less shall be capable of making 5 fade stops (10 fade stops on the second test) from 60 mph at a deceleration not lower than 15 fpsps for each stop, followed by 5 fade stops at the maximum deceleration attainable from 5 to 15 fpsps.' As you noted, S5.1.4.2(a) must be read in conjunction with S7.11.2.1, which sets forth the procedure for conducting the fade stops. It reads, in relevant part, as follows: Make 5 stops from 60 mph at 15 fpsps followed by 5 stops at the maximum attainable deceleration between 5 and 15 fpsps for each stop. ... Attain the required deceleration within 1 second and, as a minimum, maintain it for the remainder of the stopping time. Control force readings may be terminated when the vehicle speed falls to 5 mph. (Emphasis added.) The words 'required deceleration' in S7.11.2.1 refer to 15 fpsps. (That value is set forth both in S5.1.4.2(a) and the first sentence of S7.11.2.1.) Thus, in conducting fade stops, within one second of beginning a stop, a deceleration of 15 fpsps must be attained. S7.11.2.1 then specifies that, 'as a minimum,' the required deceleration (15 fpsps) must be maintained for the remainder of the stopping time. (The word 'it' in the highlighted sentence refers back to the phrase 'required deceleration.') Thus, after a deceleration of 15 fpsps is attained (within one second of beginning the stop), the deceleration cannot drop below 15 fpsps even momentarily. You stated that you are aware of the following three understandings within the industry concerning the meaning of this requirement: 1. The average deceleration for the stop must be greater than 15 fpsps. The average deceleration is calculated from one second after the stop begins to a vehicle speed of 5 mph. 2. After 1 second the deceleration can not drop below 15 fpsps even for an instant. If the deceleration drops below 15 fpsps at any time it is considered a failure even if the average deceleration is greater than 15 fpsps. 3. The average deceleration for the stop must be greater than 15 fpsps and the deceleration must be greater than 15 fpsps for at least 75% of the stop excluding the first second of the stop. Of the three understandings, the first and third are inconsistent with the plain wording of S7.11.2.1 which specifies that, after the required 15 fpsps deceleration is attained (within one second of beginning the stop), it must, as a minimum, be maintained for the remainder of the stopping time. The first and third understandings would, among other things, replace S7.11.2.1's specification that the 15 fpsps deceleration be maintained as a 'minimum' with one that it be maintained as an 'average.' The second understanding is largely correct. It is correct to state that, in conducting a fade stop, after a 15 fpsps deceleration is attained (within one second of beginning the stop), the deceleration cannot drop below 15 fpsps even for an instant. However, if the deceleration did drop below 15 fpsps, that would not necessarily indicate a 'failure' but might simply be an invalid test. As you note in your letter, a deceleration might fall below 15 fpsps because the driver did not compensate for in-stop fade. However, if a vehicle was unable to pass Standard No. 105's fade stop test requirements at the specified deceleration rates, it would not comply with the standard, notwithstanding the fact that it might be able to pass the requirements at slightly lower deceleration rates. You stated in your letter that the second understanding appears to not consider the intent of the fade procedure, the intent being that a vehicle must be capable of making multiple high deceleration stops in a short period of time without drastic changes in effectiveness. As discussed above, the purpose of the fade and recovery test requirements is to help ensure that brakes retain adequate stopping capacity during and after exposure to conditions cause by prolonged or severe use, such as long, downhill driving. If a vehicle was unable to pass Standard No. 105's fade stop test requirements at the specified deceleration rates, it would indicate inadequate stopping capability during conditions caused by prolonged or severe use, such as long, downhill driving. You also stated that in the Laboratory Test Procedure for Standard No. 105, published by NHTSA's Office of Vehicle Safety Compliance (OVSC), the data sheet for the fade stops requests the following information for the deceleration: 'Average Sust Decel.' You stated that it therefore appears that NHTSA's interpretation of the phrase 'at a deceleration not lower than 15 fpsps for each stop' is 'the average sustained deceleration.' It is incorrect to interpret the OVSC Laboratory Test Procedures as limiting the requirements of the Federal motor vehicle safety standards. I call your attention to the following note which is set forth at the beginning of the Laboratory Test Procedure: The OVSC Laboratory Test Procedures, prepared for use by independent laboratories under contract to conduct compliance tests for the OVSC, are not intended to limit the requirements of the applicable FMVSS(s). In some cases, the OVSC Laboratory Test Procedures do not include all of the various FMVSS minimum performance requirements. Sometimes, recognizing applicable test tolerances, the Test Procedures specify test conditions which are less severe than the minimum requirements of the standards themselves. Therefore, compliance of a vehicle or item of motor vehicle equipment is not necessarily guaranteed if the manufacturer limits certification tests to those described in the OVSC Laboratory Test Procedures. I am enclosing a copy of the most recent version of the Laboratory Test Procedure for Standard No. 105, in response to your request. I hope this information is helpful. If you have any further questions, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366- 2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam0113OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P.O. Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Mr. Heath: Your letter of August 19, 1968, addressed to Mr. David A. Fay, of th National Highway Safety Bureau has been forwarded to my office for reply.; The original list of definitions of vehicles was published in th Federal Register as part of a Notice of Proposed Rule Making dated December 3, 1966. Comments were requested from interested parties. Subsequently, the definition of a multipurpose vehicle was added to the Federal Motor Vehicle Safety Standards in response to a number of comments received from industry requesting a different category for certain utility vehicles. Under the previous classification, there were a number of special purpose vehicles which did not fit into any single category. It was agreed that certain types of motor vehicles, such as Dune Buggies, the Carryall, Travelall, Compact Van, Jeep Wagoneer, Ford Bronco, and Scout type vehicles comprised a hybid (sic) class of motor vehicle which possessed the characteristics of more than one of the motor vehicle categories previously established. The 'special features' include such items as 4-wheel drive amphibious equipment. Due to the differences in body construction, load time requirements, and general vehicle purpose, it was not considered reasonable to require those dual purpose vehicles designed to carry ten persons or less to meet all of the passenger car requirements, as would have been required by the Notice. For those reasons, the new category of 'multipurpose passenger vehicle' use (sic) added to Section 245(b).; Your interest in the automotive safety program of the Federal Highwa Administration is greatly appreciated.; Sincerely, Eugene B. Laskin, Acting Director, Office of Standard Preparation, Motor Vehicle Safety Performance Service; |
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ID: aiam2987OpenMr. Moe Pare, Jr., Director of Design, Cars & Concepts, Inc., 12500 E. Grand River, Brighton, MI 48116; Mr. Moe Pare Jr. Director of Design Cars & Concepts Inc. 12500 E. Grand River Brighton MI 48116; Dear Mr. Pare: This responds to your March 2, 1979, letter concerning the definitio of the vehicle sub-classification, 'convertible.' Your letter included several Figures of various vehicle designs and asked whether each would be considered a 'convertible' by the National Highway Traffic Safety Administration.; While our regulations do not include a formal definition o 'convertible', the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed rigid structural member. Therefore, passenger cars equipped with a 'sun roof' or a 'Hurst hatch roof' do not qualify as convertibles, because they have a fixed, rigid structural member in the described location (April 21, 1976, letter of interpretation enclosed). This interpretation applies, moreover, whether the rigid structural member joining the 'A' and 'B' pillars is a hidden reinforcing component or whether the structural member is part of the exterior roof panel.; Given this interpretation, only the Fiat X-19 vehicle desig illustrated in your Figure 5 would qualify as a 'convertible.' Each vehicle design in your other illustrations (Figures 1, 2, 3, 4, 5, 6, 7, 8 and 9) include fixed, rigid structural components joining the 'A' and 'B' pillar sections of the vehicles and, therefore, would not be classified as convertibles. Likewise, the designs would not be considered 'open-body type vehicles' (49 CFR 571.3) for the same reason, the structural member, whether hidden or not, would be considered part of the vehicle top. Also, I would point out that the 'open-body vehicle' designation generally refers to multipurpose passenger vehicles such as 'Jeeps' or 'dune buggies.'; I hope this clarification is responsive to your inquiry. If you hav any further questions please contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4150OpenMr. Don Black, Director, U.S. Engineering Office, Alfa Romeo, 250 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Don Black Director U.S. Engineering Office Alfa Romeo 250 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Black: Thank you for your letter of March 24, 1986, to former Chief Counse Jeffrey R. Miller about the requirements of Standard No. 208, *Occupant Crash Protection*. You explained that Alfa Romeo intends to install automatic safety belts in its two seat convertible model and asked how the requirements of Standard No. 208 apply to such an automatic crash protection. In essence, all of your questions concern whether an automatic belt system can be substituted for a Type 1 or Type 2 safety belt system under 4.1.2.1(c)(2) of the standard. The answer is yes, and automatic safety belt can be used to meet the frontal crash protection requirements of S4.1.2.1(a) and can also be substituted for a Type 1 or Type 2 safety belt to meet the requirements of S4.1.2.1(c)(2).; As provided in S4.5.3 of the standard, an automatic safety belt syste can be 'used to meet the crash protection requirements of any option under S4 and in place of any seat assembly otherwise required by that option.' Thus, an automatic safety belt can be substituted for a Type 1 or Type 2 belt system under S4.1.2.1(c)(2). Therefore, an Alfa Romeo convertible equipped with an automatic safety belt would not be subjected to the lateral crash test of S5.2 or the dynamic rollover test of S5.3.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3695OpenMr. Thomas D. Turner, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. Thomas D. Turner Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Turner: This is in response to your letter of March 10, 1983, with respect to school bus warning light system that you wish to offer in response to your understanding of Utah Senate Bill No. 70. This system would allow the school bus operator to activate only the rear warning lamps when stopping on a divided highway where no traffic is approaching from the front in an adjacent traffic lane.; In our opinion, the Utah bill (copy attached) does not require such system, and a system of this nature is not allowed by Motor Vehicle Safety Standard No. 108. The pertinent portion of Senate Bill No. 70 reads: 'The driver of a vehicle upon a divided highway or upon a highway with roadways separated by a painted median in excess of 12 feet of width need not stop upon meeting or passing a school bus which is on the other roadway.' (Sec. 2) The bill contains no reference to the number or kinds of lights that a school bus may operate in this traffic situation. As paragraph S4.1.4(b)(ii) of Standard No. 108 requires activation of lighting systems, without qualification, we interpret it as precluding a system that is capable of partial operation.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1352OpenMr. W. G. Milby, Project Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your November 8, 1973, request for a interpretation of the warning signal requirements of Standard No. 121, *Air brake systems*.; S5.1.5 of that standard states: >>>A signal, other than a pressure gauge, that gives a continuou warning to a person in the normal driving position when the ignition is in the 'on' or 'run' position and the air pressure in the service reservoir system is below 60 psi. The signal shall be either visible within the driver's forward field of view, or both audible and visible.<<<; A warning that 'the air pressure in the service reservoir system i below 60 psi' is intended to mean that a warning device's sensor could be located in the system you described in your letter between the source of air pressure and the check valve(s) required by S5.2.1.5. As you pointed out, this location would sense pressure below 60 psi anywhere from the compressor through the entire service reservoir system. A single warning installed before the check valves in a split service brake system would fulfill the requirements of S5.1.5 as long as it is positioned to sense pressure below 60 psi in any part of the split service reservoir system.; Your interpretation of the signal requirements is correct. The signa must be both audible and visible, or it must be visible within the driver's forward field of view. A simple audible signal is insufficient, as is a simple visible signal which is not within the driver's forward field of view.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4500OpenRobin C. Gelburd, Esq. Morrison & Foerster 415 Madison Avenue New York, NY 10017-1193; Robin C. Gelburd Esq. Morrison & Foerster 415 Madison Avenue New York NY 10017-1193; "Dear Ms. Gelburd: This is a response to your letter of January 12 1988, asking for NHTSA's evaluation of your client's product intended for use with an add-on child restraint system to 'cushion and insulate the child.' The product, a sample of which was enclosed with your letter, is a fabric-covered rectangular seat-pad about 1/2 inch thick, surrounded at the top and both legs by a fabric-covered cushion. The product has a crotch-strap in the front, through which is inserted a belt that anchors on the legs of the rectangle. On the back of this product are two clips apparently to be used for anchoring the seat pad to the child restraint system. You asked generally whether this product will 'contravene or compromise' Federal safety standards, particularly Standard 213, Child Restraint Systems (49 CFR 571.213). Additionally, you asked us to 'determine whether the product complies with relevant statutes and regulations within (NHTSA's) jurisdiction.' Your client's product falls within NHTSA's jurisdiction if it is an item of 'motor vehicle equipment' as that term is defined in 102(4) of the National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act). Section 102(4) defines 'motor vehicle equipment' as: ...any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component, or as any accessory, or addition to the motor vehicle. In determining whether an item is an 'accessory,' the agency assesses two factors: first, whether the item has no ostensible purpose other than use with a motor vehicle, and second, whether the item is intended to be used principally by ordinary users of motor vehicles. Applying these criteria to your client's seat-pad, we conclude that the seat-pad has no purpose other than use with a child restraint system and that it is intended to be used principally by consumers. Thus, the seat-pad would be an 'accessory,' and, therefore, is 'motor vehicle equipment' within the meaning of the Vehicle Safety Act. The Vehicle Safety Act gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard 213, which applies to all new child restraint systems sold in this country. However, Standard 213 does not apply to aftermarket items for child restraint systems, such as your client's seat-pad. Hence, your client is not required to certify that this product complies with that standard before selling the seat-pad. Although Standard 213 does not directly apply to your client's product, there are several statutory provisions of which you should be aware. First, 108(a)(2)(A) of the Vehicle Safety Act states that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard... There is an element of design incorporated in a child restraint system that may be affected by installing Hasbro's seat-pad. Standard 213 sets flame-retardant performance requirements for materials used in a child restraint system. (See 49 CFR 571.213, S7, referencing 49 CFR 571.302, S4. For your information, I enclose a copy of 571.302.) If installing this seat-pad would denigrate the flammability resistance attributes of the child restraint system, then a manufacturer, distributor, dealer, or repair business installing this product would 'render inoperative' a design element installed in the child restraint system in compliance with a Federal motor vehicle safety standard. The person who committed such an act would have violated 108(a)(2)(A), and would be subject to a civil penalty of up to $1000 for each 108 violation on each child restraint system where this design element was 'rendered inoperative.' Second, your client should know that it will be a motor vehicle equipment manufacturer if it offers this product for sale. As a manufacturer, your client will be subject to the requirements of 151-159 of the Vehicle Safety Act (15 U.S.C. 1411-1419), concerning the recall and remedy of products with defects related to motor vehicle safety. If your client or the agency determined that this seat-pad had a defect related to motor vehicle safety, your client would have to notify all product purchasers of the defect, and either: 1. repair the seat-pad so that the defect is removed, or 2. replace the seat-pad with an identical or reasonably equivalent product that does not have the defect. Your client, as the manufacturer, would have to bear the full expense of the notice-and-recall campaign, irrespective of the option chosen, for any owner who purchased the product less than eight years before the notice-and-recall campaign. Except in the context of a defect proceeding, the agency does not determine the existence of safety-related defects. Therefore, we are unable to say whether your client's seat-pad might contain such a defect. However, I wish to express my concern with one aspect of this product. The cushion that surrounds the seat pad is uninterrupted, and seems to have no provision for passing the child restraint system belt around or through the pad and cushion. If the installation of your seat-pad would impair the function of a belt installed to restrain the child, then any manufacturer, distributor, dealer, or motor vehicle repair business installing the seat-pad would render inoperative a Federally required element of design that applies to child restraint systems. That kind of action would violate 108(a)(2)(A) of the Vehicle Safety Act, and subject the offender to a civil penalty of $1000.00 for each violation. Further, the seat pad has a crotch and lap belt assembly. I think it is possible that some parents may use the belt assembly on the seat-pad as a lap restraint for restraining a child's lower torso. Given that your client's seat-pad has a belt configuration similar to that which a user might expect to see in a child restraint with a crotch strap and lap belt assembly, parents may assume that the belt meets the performance requirements that apply to belts installed on child restraint systems. For example, a nonmetallic belt buckle (such as the buckle on the Hasbro sample) in a child restraint system must meet the temperature resistant specifications of the American Society for Testing and Materials 'Standard Practice for Determination of Weight and Shape Changes in Plastic,' D756-78. (49 CFR 571.213, S5.4.2.) There are load requirements for both the buckle assembly and the webbing in a lap belt restraint system. (49 CFR 571.213, S5.4.1.) There are several other performance requirements in Standards 209 and 213 applicable to belts, buckles, and materials used on belts installed in child restraint systems. I am sure that your client will want to minimize the chances of a parent mistakenly using the seat-pad belt assembly as a torso restraint. Hasbro may choose to alert parents not to misuse the belt on the seat-pad. One possible means of alerting parents would be to affix a 'warning label' to the product. Please understand that this explanation is not an agency 'recommendation'. NHTSA does not offer its opinion as to the value or practicality of motor vehicles or equipment. When a potential motor vehicle or equipment manufacturer presents us with questions concerning a product, we use the information presented to explain how our statute and regulations may apply to such products. It is up to the manufacturer to assess the value and practicality of the product. I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam0810OpenMr. David K. Long, Consumer Microcircuits Engineer, Fairchild Semiconductor, 464 Ellis Street, Mountain View, CA 94040; Mr. David K. Long Consumer Microcircuits Engineer Fairchild Semiconductor 464 Ellis Street Mountain View CA 94040; Dear Mr. Long: This is in reply to your letter of July 26, 1972, on the subject of th situations in which S7.4.3 of Motor Vehicle Safety Standard No. 208 permits operation of the engine starting system, notwithstanding the ignition interlock requirements of S7.4.1 of the standard.; Your first question is whether the engine may be restarted if th ignition switch is turned off after the driver has left the seat. Our reply is that restart would not be permitted except within a period of three minutes after the switch has been turned off. There is no sequential relationship between the operation of the switch and the driver's leaving the seat, so that the starting system will have to become inoperable if the driver has left the seat and has turned the ignition off, regardless of whether he turned the switch before or after leaving the seat.; Your second question is whether the engine may be restarted if th ignition switch is turned off, then on, and the driver leaves his seat. Our reply is again that restart would not be permitted. S7.4.3 refers to operation 'if the ignition has not been turned off'. Once the ignition has been turned off, turning it on again will not revive the restart mode unless the engine is actually started again and then stopped with the ignition 'on'.; We have forwarded your check for a Federal Register subscription to th Superintendent of Documents. Enclosed you will find a copy of Notice 20, as you requested.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1702OpenHonorable Thomas F. Eagleton, United States Senate, Washington, DC 20510; Honorable Thomas F. Eagleton United States Senate Washington DC 20510; Dear Senator Eagleton: I am pleased to respond to your November 18, 1974, letter asking for clarification of the National Highway Traffic Safety Administration regulations that might affect disconnection of the ignition interlock and continuous buzzer in 1974- and 1975-model passenger cars. Chrysler Corporation has suggested that our regulations make disconnection more complicated than contemplated by the 'Motor Vehicle and Schoolbus Safety Amendments of 1974.'; The NHTSA has issued no regulations which govern the disconnection o any safety devices, including the ignition interlock and continuous buzzer. The only interlock or belt warning system requirements issued by the NHTSA specified installation of these safety features at the factory, and they are unrelated to disconnection of these devices by the dealer or any other person. The regulation in question (Standard No. 208, *Occupant crash protection*) specified installation of ignition interlocks until October 29, 1974, when that requirement was deleted in response to legislation enacted October 27, 1974. The regulation also specified installation of a 'continuous buzzer' until December 3, 1974, when that requirement was modified in response to the same legislation, after the new system had been proposed and had been commented on by interested persons. The new system conforms to the legislative prohibition on continuous buzzers, and it is optional until February 24, 1975, when it becomes mandatory.; The only restrictions on disconnection of safety devices are statutor and, as such, are not subject to modification by the NHTSA. Specifically, the Safety Act of 1966 prohibits sale of a vehicle which does not comply with applicable standards at the time of sale, and this effectively prohibits disconnection prior to sale (S108(a)(1)). Until the Safety Amendments of 1974 become effective on December 26, 1974, (sic); The new system consists of a continuous or flashing reminder light tha operates only during the 4- to 8-second period after the ignition is operated, and a continuous or intermittent audible warning signal which operates only during the 4- to 8-second period after the ignition is operated if the driver's lap belt is not in use. Either the old system or new system can be provided in passenger cars until February 24, 1975, when the law requires that the old system be discontinued.; Since the permissibility of disconnection is the subject of a la passed by Congress, our regulation does not address the issue. We have prepared a short discussion of the disconnection law and I enclose a copy that explains its effect. The NHTSA is, of course, not authorized to modify this law.; Thank you for your interest in motor vehicle safety. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.